|
|
| Line 18: |
Line 18: |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:_ _. -. ._-. . - _. . ,. | | {{#Wiki_filter:}} |
| DoneW C. Shohen 300 Madam Aveme ioledo, OH 43652 0001 ;
| |
| L Vce PresLient Nucier De&Besse (419)249-2300 l I
| |
| Docket Number 50-346 t License Number NPF-3 t Serial Number 1866 ,
| |
| November 5, 1990 l l
| |
| United States Nuclear Regulatory Commission l Document Control Desk ,
| |
| Vashington, D. C. 20555
| |
| | |
| ==Subject:==
| |
| Request for Temporary Exemption from Filing Requirements for '
| |
| Simulation Facility Certification Gentlemen:
| |
| The Toledo Edison Company plans to comply.vith 10 CFR 55.45(b)(2)(lii) for the Davis-Besse Nuclear Power Station (DBNPS) Unit No. 1 by certification of a :
| |
| plant referenced simulation facility in accordance with 10 CFR 55.45(b)(5)(i).
| |
| flovever, due to special circumstances regarding the manufacturing and software j programming of the simulator, the March 26, 1991-deadline for submitting Form .
| |
| NRC-474, " Simulation Facility Certification" will not be achieved.. ;
| |
| The Toledo Edison company hereby requests a temporary. exemption from the . -
| |
| filing requirements of 10 CFR 55.45(b)(2)(iii) to allow for the submittal of Form NRC-474, " Simulation Facility Certification" after.the March 26, 1991 i deadline provided in the regulation. Pursuant to Generic Letter Number 90-08, Simulation Facility Exemptions, the requirements of 10 CFR 50.12(a)(2)(v),
| |
| have been addressed whereby, the Nuclear Regulatory Commission may upon J application, grant an exemption when the exemption vould provide only 1 temporary relief from the applicable regulation and the licensee has made good I faith efforts to comply with the regulation. ,
| |
| Toledo Edison has made good faith efforts to comply with-10 CFR 55.45(b)(2)(iii) and requests a temporary exemption from filing Form NRC-474 until September 1, 1991. This date is 60 days prior to the DBNPS's first scheduled operator license examinations to be administered on the simulator. _The means for conducting !
| |
| operator examinations vill not be affected by this delay, as the DBNPS's May l operator examinations are scheduled to be administered prior to May 26, 1991'(the j deadline for using a noncertified or' unapproved simulation facility under i 10 CFR 55.45(b)(iv)). The importance of ensuring that the May 1991 NRC operator 1 examinations are conducted prior to May 26, 1991, was discussed by Toledo Edison J representatives and Mr. T. Burdick, NRC Region III on October 23, 1990. These l examinations are currently scheduled for the_veek of May 13,.1991. No other ]
| |
| - examinations requiring the use of the simulator are scheduled between May 26,' 1991 and November 1, 1990. !
| |
| 90.1113o213 9011os POR ADOCK 05000346 l
| |
| - opena cbneur P ppc /,,g i:
| |
| Otwetond Doctne lilummotmg iI Q-Toledo Edison -
| |
| | |
| ~
| |
| Docket Nu;ber 50-346
| |
| ., Lic nsa Nuxber NPP-3 Serial Number 1866 Page 2 P
| |
| There are several special circumstances responsible for the delay in the schedule. Completion of the simulator specification contract took six months longer than expected as it involved extensive negotiations that involved two other utilities purchasing common simulators at the same time from the same vendor (CAE Electronics, Ltd.). The initial simulator schedule vas established prior to the June 9, 1985 DBNPS Loss-of-Feedvater Event. After >
| |
| this event, the resulting eighteen-month vork outage and restart effort diverted Toledo Edison manpover from the simulator project. Additional manpover was diverted from the simulator project to support operations during the 1986 bargaining unit strike. Due to these unplanned circumstances, the simulator purchase order was not placed until August 1, 1986. It was accepted by the simulator vendor on September 5, 1986.
| |
| Toledo Edison advised the Nuclear Regulatory Commission (NRC) on June 1, 1988, (letter Serial Number 1530) and on July 13, 1988, (letter Serial Number 1548) that the simulator installation vould again be delayed. At that time, Toledo Edison stated that the simulator was expected to be installed in the DBNPS Nuclear Training Center by June 30, 1989, and be ready for training use by December 31, 1989. Following this notification, delays on the simulator occurred due mainly to problems the vendor encountered during software development and software / hardware integration. As a result, Toledo Edison had to postpone the simulator installation until January 1990, beyond the end of the Fifth Refueling Outage (September, 1988).
| |
| As a result of the delay in the installation, a decision was made to upgrade the simulator to reflect the Fifth Refueling Outage modifications prior to making it available for training use. The Fifth Refueling Outage ,
| |
| modifications require simulator hardware and software changes that involve replacement of meters, relocation of instrumentation, installation of new svitches, indicating lights, etc. These modifications are necessary due to 93 plant modifications and the resulting modifications made to the DBNPS Control Room. They included extensive changes made to the Auxiliary Feedvater System, the Steam and Feedvater Rupture Control System, Feed and Bleed Cooling, and resolution of numerous human engineering deficiencies as part of the post THI-2 required Detailed Control Room Design Review. This upgrade is planned to be completed by December 1990.
| |
| After the simulator is shipped, currently planned for January 10, 1991, it vill require reassembly, a complete checkout, reverification testing, and the '
| |
| performance of an availability test. After these activities are complete, Toledo Edison plans to install selected Sixth Refueling Outage (January -
| |
| July, 1990) upgrades prior to releasing the simulator for training use. The selected changes, which vill include the rearrangement of a major percentage of control room annunciators, relocation of several important switches, and the addition of an alternate makeup system injection line to the reactor coolant system, are considered to have a negative impact on training quality if not incorporated prior to training use. Since installation of these changes is precluded by post delivery activities until May 1991, these modifications vill be developed, installed, and certification tests performed in preparation for Form 474 submittal in September 1991.
| |
| | |
| ~
| |
| 1 Dock t Nunber 50-346 Llesnse Nuab2r NPP-3 Serial, Number 1866 ,
| |
| Page 3 Toledo Edison believes that the delays experienced to date vere unavoidable l and that the remaining upgrade to include the extensive plant modifications are necessary and vill provide a more suitable plant specific simulator.
| |
| The granting of this requested extension for filing Form NRC-474 vill not
| |
| , endanger public health and safety and is consistent with the common jefense and security. The Nuclear Regulatory Commission has itself rer6 nized in the Supplementary Information published along with the Final Rule to 10 CFR 55.45 that unique circumstances may arise on a plant-specific basis that causes some deviation from the certification time established in the i'
| |
| rule. Vhere, as in this case for the DBNPS, the licensee has made reasonable efforts to comply with the illing requirements and otherwise intends to fully comply with 10 CFR 55.45, such exemption should be granted. Therefore, Toledo Edison requests a temporary exemption from 10 CFR 55.45(b)(2)(iii) until September 1, 1991.
| |
| 4 Should you have any questions or require additional information, please contact Mr. R. V. Schrauder, Manager - Nuclear Licensing, at (419) 249-2366.
| |
| Very truly yours,
| |
| , 7 FVK/mmb cci P. H. Byron, DB-1 NRC Senior Resident Inspector A. B. Davis, Regional Administrator, NRC Region III H. D. Lynch, DB-1 NRC Senior Project Manager Utility Radiological Safety Board i
| |
| 6 h
| |
| .}}
| |
